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16 TO CONRAD MURRAY: 17 PLEASE TAKE NOTICE that Michael Joseph Jackson, born August 29, 1958, and died June 25, 18 2009, was under your care and received medical treatment from you from sometime prior to December, 19 2008, through June, 2009. Plaintiffs, Joseph Jackson, and other survivors of the deceased Michael Jackson 20 who may wish to join with him, submit the following Notice of Intent to Initiate Legal Proceedings 21 pursuant to the requirements of Code of Civil Procedure section 364. This suit will be instituted 90 days 22 from the date of this notice unless their claims and damages are resolved. 23 PARTIES 24 1. On June 25, 2009, Joseph Jackson was the biological and natural father of decedent, Michael 25 Joseph Jackson, and the dependent parent of Michael Joseph Jackson supported as provided in Code of 26 Civil Procedure section 377.60. 27 2. On that date, Michael Joseph Jackson, was the biological son and natural child of Joseph 28 Jackson, and under the care and treatment of defendant, Conrad Murray, a physician. _________________________ 1 _________________________ NOTICE OF INTENT TO INITIATE LEGAL PROCEEDINGS

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3. On that date, defendant Conrad Murray, was a physician licensed to practice medicine in the

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State of California and engaged in the practice of medicine in the County of Los Angeles, State of

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California, treating decedent, Michael Joseph Jackson.

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STATEMENT OF THE CASE 4. Defendant Murray has given multiple and contradictory versions of the times and events which

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lead to Michael Jackson’s death. Each contradiction demonstrates a reckless disregard for Michael

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Jackson’s life. The changing of times, dates, and events have taken place only because defendant willfully

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failed to keep medical records in violation of California Business and Professions Code section 2266.

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A. Defendant’s Misrepresentations to and Concealment from Paramedics. 1. The initial emergency 911 call. 5. On June 25, 2009, at 12:22 p.m., the Los Angeles Fire Department received a 911 call from

California. He stated that a 50-year old “gentleman” was not breathing and that he needed emergency

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assistance. Alvarez did not state the address of the location, and he did not identify himself or the

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“gentleman” to whom he was referring.

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6. Alvarez said the patient was under the care of a doctor who was administering cardio-pulmonary

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resuscitation (CPR) on the bed. The 911 operator said the patient should be removed to the floor. The

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operator said CPR should be continued under the doctor’s care, and paramedics were on the way.

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7. The Fire Department immediately responded to the 911 call. The paramedics arrived at 100 N. Carolwood within four (4) minutes at 12:26 p.m. They were at Michael Jackson’s bedside at 12:27 p.m. 8. Michael Jackson was not breathing, his color was pale, and he was in cardiac arrest. The level of his condition was “severe.” His pupils were fixed and dilated. He had no detectable pulse or respirations. 2. Defendant’s false statements to Paramedics.

(Romazicon), and Flomax (Tamsulosin Hydrocloride). Defendant’s statements to the paramedics, who

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were relying upon him to attempt to save Michael Jackson’s life, demonstrated a reckless disregard and

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endangerment of Michael Jackson’s life which impaired their rescue efforts.

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3. The Paramedics’ rescue efforts.

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11. At 12:29 p.m., the paramedics began their resuscitation. Michael Jackson had no pulse, blood

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pressure, respirations, or oxygen saturation reading, and his heart was in PEA (pulseless electrical activity)

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with no contractions. Michael Jackson’s condition remained unchanged throughout the resuscitation

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except that at 12:34 p.m., the PEA had ceased and his heart was in asystole (no heart beat).

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12. The paramedics administered several cardiac stimulating drugs without effect. At 12:50 p.m.,

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the paramedics contacted UCLA Medical Center, and described the absence of any life signs from Michael

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Jackson. Dr. Richelle Cooper, who was head of the UCLA Emergency Department, told the paramedics to

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consider terminating their resuscitation efforts.

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13. Defendant Murray stated to the Paramedics that he would be responsible for further

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resuscitation efforts. The Paramedics then placed Michael Jackson in the ambulance at 13:07 hours or 1:07

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p.m., and the Paramedics again attempted resuscitation without success. The ambulance arrived at UCLA

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Medical Center at 13:13 or 1:13 p.m. Throughout the entire resuscitation effort, defendant concealed the

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drugs he had administered to Michael Jackson in violation of Penal Code section 148(a)(1).

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B. Defendant’s Misrepresentations to and Concealment from UCLA Doctors. 1. Defendant’s false statements to Dr. Cooper. 14. On June 25, 2009, at 13:15 hours or 1:15 p.m., the paramedics brought Michael Jackson into

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the UCLA emergency room. Defendant Murray was present, and in his presence Michael Jackson was

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identified to UCLA personnel under the false name Soule Shaun. The attendants noted that while there was _________________________ 3 _________________________ NOTICE OF INTENT TO INITIATE LEGAL PROCEEDINGS

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a cardiologist at the scene, he provided no medical history. Such conduct was an extreme violation of the

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standard of care.

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15. Michael Jackson had no pulse, blood pressure, spontaneous respirations, or heart beat. He was

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given several drugs including dopamine, epinephrine, atropine, vasopressin, and sodium bicarbonate, and

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he his breathing was assisted by bagging with oxygen. He was not alert, his pupils were fixed and dilated,

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and he had no response to pain.

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16. Dr. Richelle Cooper, the head of the UCLA Medical Center Emergency Department, spoke to

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defendant. Defendant told Dr. Cooper he had felt a pulse for Michael Jackson when he had discovered him

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not breathing. He stated he had only administered Lorazepam (Ativan), Diazepam (Valium), and Flomax.

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17. Defendant said nothing about Propofol and nothing about Flumazenil (Romazicon), or the other

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drugs found in Michael Jackson’s body at his autopsy. Defendant’s conduct was an extreme departure

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from the standard of care. Defendant demonstrated a reckless disregard for Michael Jackson’s life by

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concealing the Propofol and the “polypharmacy” Michael Jackson had received for months.

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18. Dr. Richelle Cooper’s written report dated June 26, 2009, stated: “The initial limited history was provided by Dr. Murray, during the resuscitation of the

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patient, and is noted in brief on the medical record. By report of Dr. Murray the patient had been

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working long hours but had not been ill.. There was no reported trauma or seizure activity

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preceding the arrest. The only reported medications reported for the patient were valium and

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flomax. There is no history of drug use by the patient as reported by Dr. Murray. The events

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surrounding the arrest, reported by Dr. Murray was that he had placed an I.V. and given the patient

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2 mg of lorazepam IV. Sometime earlier in the day Dr. Murray then administered a second 2mg

19. Defendant’s statements to Dr. Cooper were outrageous. Defendant’s statements were false and

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misled emergency personnel. Michael Jackson had also been ill. The statements demonstrated a high

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degree of recklessness that shocks the conscience and were an extreme departure from the standard of care.

26 27 28

2. Defendant’s statements to Dr. Cooper contradicted his police statement 20. Defendant told police on June 27, 2009, two (2) days later, he was afraid Michael Jackson was addicted to Propofol. He had a long history of addiction, and defendant was trying to wean him off the _________________________ 4 _________________________ NOTICE OF INTENT TO INITIATE LEGAL PROCEEDINGS

1 2

drugs. Yet, he told Dr. Cooper two (2) days earlier that Michael Jackson had no drug use history. 21. Defendant’s history of prescriptions to Michael Jackson went back to December, 2008, and

3

likely earlier. When police searched Michael Jackson’s home following his death, they seized dozens of

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drug vials showing Michael Jackson’s exorbitant drug use. Some of the vials showed that on December 22,

fingers. Alberto Alvarez told police defendant asked him to call 911 only after the drugs were concealed.

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41. The Los Angeles Fire Department recorded the 911 telephone call at 12:22 p.m., which

27

was approximately one (1) hour and thirty (30) minutes from the time defendant Murray claimed he found

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Michael Jackson not breathing at 10:52 a.m. Defendant Murray told the Detectives several times that it _________________________ 8 _________________________ NOTICE OF INTENT TO INITIATE LEGAL PROCEEDINGS

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was around 11:00 a.m. that he found Michael Jackson not breathing. Defendant Murray’s statement was

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specific and made in the calm of an interview with his attorneys present.

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42. Under defendant’s original version, more than one (1) hour and thirty (30) minutes elapsed

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between discovering Michael Jackson not breathing and the 911 telephone call. In that time defendant

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made three (3) telephone calls, which he concealed from police, to other individuals consuming 47 minutes

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of talk time according to his telephone records. Defendant concealed evidence of his unlawful drug

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administration. His conduct was inhuman. It was an extreme violation of the standard of care.

8

E. Defendant’s Revised Version of Events.

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43. When defendant discovered there were telephone and other records which exposed his

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outrageous actions, defendant claimed that despite his interview by Los Angeles Police on June 27, 2009,

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he got his story wrong. He then changed his story in an attempt to comport his claims to the telephone

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records the police obtained. The reason defendant felt he could change his story was because he kept no

conversations with others where he didn’t notice that Michael Jackson had stopped breathing.

27 28

47. Defendant’s conduct under this new version of the story was more ominous and reckless than the first. The administration of Propofol requires a measured infusion using a mechanical pump which _________________________ 9 _________________________ NOTICE OF INTENT TO INITIATE LEGAL PROCEEDINGS

1

is constantly monitored because of unpredictable changes in the patient’s blood pressure. Instead, he

2

infused the drug by I.V. drip and syringe, without monitoring or resuscitation equipment, rendering it

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inherently dangerous. He recklessly endangered Michael Jackson’s life by talking on the telephone outside

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of Michael Jackson’s immediate presence for 47 minutes while a Propofol “drip” infusion took place, and

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he did not notice that Michael Jackson had stopped breathing. There was no evidence of standard of care

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monitoring which would be required when Propofol is administered.

7 8 9

F. Defendant Recklessly Concealed his Conduct and the Dangers Involved. 1. Defendant concealed the dangers from Michael Jackson 48. On June 25, 2009, prior to treating Michael Jackson, defendant was at a “strip club” called

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“Sam’s Hofbrau” in Los Angeles where he had been “drinking.” It was reckless for him to “drink” prior to

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administering anesthesia to Michael Jackson. He concealed his conduct from Michael Jackson.

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49. Defendant failed to explain to Michael Jackson the risks and benefits regarding Propofol or to

(Versed), which he had administered to Michael Jackson. Propofol interacts adversely with Ephedrine,

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which keeps a patient awake, and Nordiazepam (Calmday), both of which the Coroner’s toxicology screen

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found in Michael Jackson’s system. Defendant knew Michael Jackson was taking other drugs which were

8

contraindicated with the administration of the drugs defendant administered.

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53. Defendant concealed the inherently dangerous drug interactions. His conduct was an extreme departure from the standard of care. Defendant acted with reckless disregard for Michael Jackson’s life. G. The Coroner’s Autopsy Findings.